An NRC-identified non-cited violation of
10 CFR 50.65(a)(4) was identified for the licensees failure to provide adequate guidance to perform an appropriate risk assessment associated with the repair of a
through-wall leak on the Unit 2 Standby Shutdown Facility(SSF) auxiliary
service water (ASW) pump discharge line which rendered the Unit 2 SSFASW system unavailable. The licensee initiated Problem Investigative Process reports (
PIPs) O-09-6393 and O-09-6003 to evaluate this issue. The inspectors determined the licensees failure to provide adequate guidance to subsequently perform an appropriate risk assessment was a performance deficiency. The failure to provide guidance to adequately assess and manage risk was determined to be greater than minor because, if left uncorrected, it had the potential to
lead to a more significant safety concern in that risk management actions to protect risk-significant equipment would not have been timely implemented. The inspectors assessed the finding using
IMC 0609, Appendix K, Maintenance Risk Assessment and Risk Management
Significance Determination Process, and determined that the finding was of very low safety significance (Green) based on the calculated incremental core damage probability being less than
1X10-6 and the additional risk management actions that were implemented. This finding also involved the cross-cutting aspect of failing to appropriately plan work activities by not fully incorporating risk insights as described under the Work Control component of the Human Performance cross-cutting area
H.3(a)